AML training

It is a requirement under Regulation 24 of the 2017 Money Laundering Regulations (as amended) to take appropriate measures to ensure relevant employees are:

  • Made aware of the law relating to money laundering and terrorist financing and to the requirement of data protection which are relevant to the implementation of the Regulations, and
  • Regularly given training in how to recognise and deal with transactions and other activities and situations which may be related to money laundering and terrorist financing.

There is no definition of what ‘regularly’ means in relation to training. The IPA recommends that regularly should mean that annual training is undertaken to reaffirm the main principles and to ensure that areas of high risk to your firm are reiterated.

You must also keep a record in writing of the measures taken of the training given, and it is recommended that the record should show the date of the training, whether it was in person or online, and details of the score of any test element. IPs should also ensure that AML training is included as part of your CPD record.

Please remember that the AML training record will be reviewed as part of any AML specific inspection visit or AML compliance review, and may be reviewed as part of an general inspection, so the record must be kept up-to-date. It is usual for the training record to be held by the firm’s Nominated Officer.

The IPA would also recommend that there is a check or test made of the effectiveness of training provided to staff. Checking the knowledge and understanding from a training session will allow you to see if the training was effective and may also highlight specific areas where extra training is required for the team, or on an individual basis.

The IPA would also recommend that specific training is sourced for the firm’s appointed Nominated Officer so that they are able to effectively carry out their enhanced role. Again any such training should be evidenced on the training record (and an IP’s CPD record where they act as the Nominated Officer).

Finally, please ensure that you have a policy in relation to providing initial AML training and information to new members of staff or staff returning from long-term absence.